Emerging markets are driving the global economy in the current world.  India has been increasingly recognised as one of the key emerging markets and is known not only for its strong offshore services sector but also for its domestic market. While on one hand, organisations are continuously developing new business strategies to meet changing market dynamics, on the other hand, tax authorities, especially in India, are responding with increased compliance requirements and ambitious audits. In such times transfer pricing (TP) has emerged as one of the largest focus area for organisations, in achieving their business objectives, and for tax authorities, to safeguard their tax bases.

PwC serves as a partner in assisting taxpayers for addressing TP issues and in building shareholder value.  PwC India is one of the leading tax services firm in India.  It has one of the largest TP teams in the world, housing over 200

PwC’s Value Chain Transformation™ product focuses on transforming the way a company does business, from strategy through delivery to customers, in a tax efficient manner. This involves leveraging PwC’s resources across geographic and service lines to create a "one-stop-shop" for professional advice and knowledge.
In the structuring and modeling arena, PwC has assisted corporates to develop business models aligned with ‘economic substance’, offering implementation support in transitioning business models and evaluating permanent establishment exposures.  Such restructuring demands an extensive knowledge on Indian tax and TP matters and access to a strong global network of expert professionals, one of PwC’s core strengths.

The increasing importance to Intellectual Property (IP) has brought to surface several critical issues. PwC’s assistance includes  IP Migration – including analysis of third party IP valuation, review of inter-company agreements, and setting up TP policy post IP migration together with tax advice on related issues such as capital gains, VAT and withholding taxes; IP Structuring – identifying and analysing commercially useful intangibles and suggesting appropriate holding structures for such intangibles; IP Planning, devising strategies for patented and non-patented IP including cost sharing arrangements, licensing structures and buy-out payments.

In addition to being a proactive documentation partner, PwC provides support in relation to defending existing TP strategies.  PwC assists taxpayers in strategizing and representing cases before the Tax Authorities and at the Competent Authority stage.

Other PwC offerings include performance of diagnostic reviews of global operations and recommending appropriate TP models.  Such review includes various aspects such as the taxpayer’s litigation history, viability of Advance Pricing Arrangements, permanent establishment exposure and simulating model profit, tax and cash scenarios. PwC also assists in preparing TP reports for FIN 48 purposes, review of management support cross charges and identifying shareholder / stewardship costs and preparing TP documentation for global energy producers, specializing in trading of critically deficient power and global carbon offsets market.

PwC’s extensive and holistic services offerings, its strong global network, cordial relationships with tax authorities and recurrent success in winning complex and critical matters at litigation stage, have carved a niche for itself as a leader in the TP arena.  Its rich experience in establishing creative and efficient tax structures continues to sustain its leadership across industries and maintains its position as the reliable transfer pricing local and global partner of choice.